State v. Latham

2025 Ohio 495
CourtOhio Court of Appeals
DecidedFebruary 14, 2025
DocketL-24-1124
StatusPublished
Cited by3 cases

This text of 2025 Ohio 495 (State v. Latham) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Latham, 2025 Ohio 495 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. Latham, 2025-Ohio-495.]

IN THE COURT OF APPEALS OF OHIO SIXTH APPELLATE DISTRICT LUCAS COUNTY

State of Ohio Court of Appeals No. L-24-1124

Appellant Trial Court No. CR0202302354

v.

David Latham DECISION AND JUDGMENT

Appellee Decided: February 14, 2025

*****

Julia R. Bates, Lucas County Prosecuting Attorney, and Evy M. Jarrett, Assistant Prosecuting Attorney, for appellee.

Sheldon S. Wittenberg, for appellant.

ZMUDA, J.

I. Introduction

{¶ 1} This matter is before the court on the state of Ohio’s appeal, pursuant to R.C.

2945.67, challenging the dismissal of the indictment by the Lucas County Court of

Common Pleas on April 30, 2024. Finding no error, we affirm. II. Facts and Procedural History

{¶ 2} On May 3, 2023, police conducted a traffic stop of appellee, David Latham,

and he was later indicted on one count of improperly handling firearms in a motor

vehicle, in violation of R.C. 2923.16(B) and (I) and R.C. 2923.111, a felony of the fourth

degree. Latham filed a motion to acquit on April 1, 2024, which the trial court construed

as a motion to dismiss under Crim.R. 12(C).

{¶ 3} On April 23, 2024, the trial court held a hearing on the motion. The state

orally opposed the motion at hearing, having filed no brief in opposition. Prior to

argument, the parties stipulated to the underlying facts in the trial court, as follows:

THE COURT: It’s my understanding that the detective that would be necessary for testimony is unavailable … this morning, however, the parties have discussed some stipulations to the facts that would have been elicited through testimony from the officer? [PROSECUTOR]: Yes, Your honor. The parties, I believe, are prepared to stipulate that Mr. Latham was stopped on May 3rd, 2023, at Avondale and Brookley in Toledo, Lucas County. David Latham was driving his vehicle – or a vehicle, a firearm and two rounds of 9-millimeter ammunition were on the front passenger seat next to him. Further, defendant has two previous convictions, both misdemeanors of the first degree, representing an attempt – a lesser charge of attempt to commit a felony offense of trafficking in cocaine. One of those convictions was on August 5th, 2021, in Toledo Municipal Court, CRA2107288. The other was on September 15th, 2017, in Toledo Municipal Court CRA17-112790101. THE COURT: And anything related to whether or not the defendant was intoxicated or under the influence at the time of this stop? [PROSECUTOR]: Your Honor, I did not see any indication of that in the records related to this case. THE COURT: So the parties are willing to stipulate that there’s no evidence that he was under the influence at the time of the stop? [DEFENSE COUNSEL]: That’s correct, Judge. THE COURT: Very well, [Defense], you’re in agreement with the stipulations as read on the record by [the Prosecutor]? [DEFENSE COUNSEL]: It’s factually accurate, Your Honor.

2. THE COURT: Very well. Given the stipulations by the parties, I find that there’s no need for further testimony by the officer in this matter.

{¶ 4} In seeking dismissal, Latham cited to State v. Barber, 2023-Ohio-2991 (6th

Dist.), a case involving a similar constitutional challenge to R.C. 2923.16, but based on

distinguishing facts, including the defendant’s failure to assert the challenge in the trial

court and his admission that he was not a qualifying adult as defined under R.C. 2923.111

because of his marijuana possession at the time of the offense. Barber at ¶ 27. The facts

in Latham’s case, therefore, presented a stronger constitutional challenge. As to the facts

in his own case, Latham argued that a prohibition against his right to open carry in Ohio

based on a misdemeanor drug conviction violated his Second Amendment rights, relying

on the authority of New York State Rifle & Pistol Assoc., Inc. v. Bruen, 597 U.S. 1 (2022)

and United States v. Daniels, 77 F.4th 337 (5th Cir.2023).

{¶ 5} The state argued that the prohibition at issue was specifically authorized by

Bruen and District of Columbia v. Heller, 554 U.S. 570 (2008), as the United States

Supreme Court permitted restrictions on firearms that aligned with the historical tradition

of concealed carry restrictions. The state argued that the improper transport charge was “a

form of concealed carry,” and that there was historical precedent permitting states to

“eliminate one kind of public carry, concealed carry, so long as they left open the option

to carry openly.” The state further mentioned regulations “regarding the transportation of

firearms” as “historical analogue.” The state cited to no precedent beyond Bruen and

Heller, however, and provided no examples of “historical analogue” to the restriction it

wished to enforce against Latham, improperly transporting firearms based on Latham’s

3. prior, misdemeanor convictions for attempted drug offenses. Furthermore, the state

argued Latham’s conduct was an impermissible “concealed carry,” without elaborating on

this argument.

{¶ 6} At the close of the hearing, the trial court entered findings on the record,

stating:

The motion that’s pending before the Court, which was captioned as a motion to acquit, is being construed by the Court as a motion to dismiss under Criminal Rule 12C. The Court makes a finding that defendant’s actions are those covered under the protections provided by the Second Amendment, that he’s included in the people that’s contemplated by that amendment. In reviewing the US Supreme Court, [Bruen], the Court announced the test that it would use to determine if a regulation violates the Second Amendment. To pass muster, the State must show that the firearms regulation is part of historical tradition and the limits and the outer bounds of the rights to keep and bear arms. The Court finds that United States versus Daniels that was cited by defense counsel’s motion out of the Fifth Circuit, 77 F.4th 337, is instructive in this case. In that matter, the Fifth Circuit found that the founders were familiar with intoxication via alcohol, but not familiar with intoxication through marijuana or other controlled substances, and the Court must look to similar harm from alcohol that the founding generation confronted through these regulations. The Daniels Court analyzed that regarding alcohol and gun possession that regulations fell into two tracts, one was the misuse of weapons while intoxicated, and then the discipline of State militias, and the regulations against misuse of weapons while intoxicated only applied to people while they were intoxicated, and the discipline and regulation of militias only dealt with those people that were in currently in active service. The Court there did not find that there was a historical tradition to ban a person from having a weapon unless they were currently intoxicated. The Daniels Court found that the same was true during the reconstruction period and that the regulations there only banned those that were currently intoxicated from possessing weapons. The Daniels Court finally concluded that 18 U.S.C. 922

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2025 Ohio 495, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-latham-ohioctapp-2025.